Modern Slavery Policy 

STAR Injury Management (The Company) is an Australian accredited workplace rehabilitation provider incorporated in Australia, who is committed to empowering people to help them over the physical and psychological hurdles that can present as barriers to returning to work after injury.

The Company recognises that freedom from slavery is a fundamental human right. Although not a reporting entity under the Modern Slavery Act (2018), it is Company policy to respect human rights within our operation and as a part of our business dealings with our “supply chain” (the products and services (including labour) that contribute to the Company’s own products and services). Situations where coercion, threats or deception are used to exploit victims and undermine their freedom, such as slavery, servitude, child labour, forced labour, human trafficking, and any related exploitation, will not be tolerated by the Company.  

To achieve this objective, we will:

• Conduct due diligence to identify and assess the risk of modern slavery in our business and supply chain, and where required implement responsible reasonable actions to avoid, prevent, mitigate and, where appropriate, remedy modern slavery where identified.
• Ensure all Company Team Members have a positive working environment within our operations that respects their rights and freedoms and ensure that the Company meets or exceeds the requirements of the Fair Work Act (2009), any applicable awards or legislative employment requirements, regarding employment contracts, agreements, and conditions (including health and safety). This includes, but is not limited to:
• Not on-charge recruitment fees to workers.
• Engage in sham contracting.
• Not undertaking unlawful wage deductions or underpayment.
• Maintain a current:
• Copy of our Modern Slavery Policy on the Company’s website.
• Modern Slavery Risk Register, that maps key parts of the operations and supply chains, records modern slavery processes and the annual modern slavery review results.
• Code of Conduct aligned with current community expectations, that sets the ethical standards of conduct within the business, that shall apply to all members of the Company.
• Grievance Guideline, so that people may safely raise concerns and report incidents about the impact the Company is having on them, including workers in supply chains. 
• Provide fit for purpose modern slavery awareness training to persons with procurement responsibilities, so that they may understand:
• What modern slavery is.
• What modern slavery looks like in a supply chain.
• How to reduce modern slavery risks in procurement.
• How to build supportive, transparent, and collaborative relationships with suppliers, including encouraging suppliers to be open about modern slavery risks.
• How to clearly communicate the Company’s expectations regarding modern slavery to suppliers.
• The importance of ensuring that modern slavery issues are specifically addressed in supplier contracts. 
• How to work with suppliers to check how they are progressing any actions they have put in place to address modern slavery risks. 
• When and how to report a concern to management regarding modern slavery. 
• Arrange the procurement of goods and services from companies based in Australia, where possible, in recognition that Australia has a strong record of respecting human rights, and the risk is low that an Australian business is conducting modern slavery practices.
• Conduct an initial Supplier Modern Slavery Risk Assessment when sourcing a new first-tier supplier with whom we have a direct contractual relationship, and either excluding suppliers or implementing safeguards when significant risk has been identified.
• Apply a continuous improvement approach to modern slavery risks so that our response over time improves by conducting an annual review that assesses and addresses our modern slavery risks and record this information in the Modern Slavery Risk Register. This review shall include, but is not limited to:
• Setting annual KPIs covering the implementation of modern slavery processes or opportunities for improvement (OFI), as well as our responses to possible cases.
• Conducting an internal audit of our supplier screening, including reviewing initial Supplier Modern Slavery Risk Assessments to determine if mitigation measures have been consistently actioned.
• Completing a risk assessment of existing first-tier supply chain entities with whom we have a direct contractual relationship, for modern slavery risks.
• Conducting a desktop review of modern slavery risks to identify OFI, allocating OFIs to responsible senior persons for action and assessing the effectiveness of implemented OFIs that have occurred in the previous year including measuring outcomes and deadlines.
• Maintain a process for responding to an identified or potential case of modern slavery, including thoroughly investigating, and where appropriate, terminating the relationship and reporting the case to a responsible national or international authority.
• Investigate any suspected breach of this policy, and where substantiated, apply appropriate disciplinary action/s as per the Company Ad-hoc Performance Management Guidelines.